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Department of Medical Assistance Services
 
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Board of Medical Assistance Services
 
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10/14/26  12:45 pm
Commenter: Anonymous

Opposition to Transitioning Service Facilitation to Insurance Company-Provided Support Brokers
 

I am writing to express my strong concern regarding the proposed transition from independent Service Facilitators to Support Brokers employed or contracted through insurance companies. As someone who has worked in healthcare since 1998 and has served as a Medicaid Service Facilitator for the past 16 years, I have witnessed firsthand the importance of maintaining independent, person-centered support for individuals receiving Medicaid waiver services.

Throughout my career, I have dedicated myself to helping individuals and families navigate complex Medicaid systems, secure services, maintain health and safety, and remain successfully in their homes and communities. The relationships that Service Facilitators develop with the individuals they support are built over many years and are based on trust, consistency, and a deep understanding of each person's unique needs.

One of my greatest concerns is the impact this change will have on the individuals receiving services. Many of my clients have intellectual disabilities, developmental disabilities, mental health conditions, or medical complexities that make adapting to change extremely difficult. Some have worked with the same Service Facilitator for many years and rely on that established relationship for stability and support. Several of my clients have already expressed fear, confusion, and frustration regarding the possibility of losing the Service Facilitator they chose and trust.

Virginia has long promoted the principles of person-centered planning and individual choice. Removing the ability of individuals and families to select their own Service Facilitator appears to contradict those principles. The current system allows individuals to work with professionals who know their history, understand their goals, and advocate on their behalf independently. Transitioning these services to insurance company-employed Support Brokers raises concerns about conflicts of interest and whether decisions will remain fully person-centered.

Service Facilitators currently serve as neutral advocates who assist individuals in obtaining the services they need. We collaborate with families, providers, physicians, and managed care organizations while maintaining our primary focus on the individual receiving services. Under an insurance company model, there is a concern that the independence of this role may be diminished. Individuals deserve advocates whose sole responsibility is supporting their health, safety, and quality of life.

In addition, many Service Facilitators possess years, and in some cases decades, of experience working within Virginia's Medicaid waiver system. This knowledge cannot easily be replaced. Experienced Service Facilitators understand local resources, provider networks, crisis prevention strategies, waiver requirements, and person-centered planning practices. Replacing these established professionals risks creating service disruptions that could negatively impact vulnerable individuals and their families.

The transition may also place additional stress on family caregivers who already struggle to navigate a complex healthcare system. Family members often depend on Service Facilitators to answer questions, solve problems, coordinate services, and respond during emergencies. Losing these established relationships will likely increase anxiety for many families and could result in gaps in communication and service delivery.

I respectfully urge Virginia policymakers to reconsider this transition or, at a minimum, allow individuals and families to continue receiving services from their current Service Facilitators if they choose. Preserving choice, continuity of care, and independent advocacy should remain priorities within Virginia's Medicaid waiver system.

After nearly three decades working in healthcare and sixteen years as a Service Facilitator, I firmly believe that maintaining independent Service Facilitation services best serves the interests of the individuals and families who depend on Medicaid waiver supports every day. Their voices, preferences, and relationships should be respected and protected throughout any system changes.

CommentID: 242378